Personal Information Protection Policy (Privacy Policy)

As KITERETSU Inc., (“Company”) handles the personal information ,etc. (“User Information”) in connection with the services, goods, and websites it provides (“Company Services”), it considers the protection of such personal information and privacy to be one of its most important duties, and in order to adequately safeguard the User Information, hereby establishes the following Personal Information Protection Policy, to work for the protection of such information:

1. When collecting User Information from the customers, the Company will clarify the purpose of use thereof, and will only collect the same to the extent necessary.
2. The Company will use the User Information collected from the customers only for the purposes of use as described below or within the purpose to be separately agreed upon by the customers.
3. The Company will take appropriate measures to prevent and cure any unauthorized access to, or loss, deletion, falsification or leakage of User Information.
4. The Company will comply with the laws regarding protection of personal information, as well as all other relevant laws, and other rules.
5. The company will appropriately manage the handling of User Information by appointing a person to be in charge of the protection and management thereof;
6. In order to improve and enhance the User Information protection system, the Company will comply with the “Personal Information Protection Regulations” and improve the same on a continuous basis

Collection of User Information

(1) User Information collected through input of information by customers

In the course of providing the Company Services and support to the customers, the Company may collect User Information through the input of information by customers. The types of User Information collected in connection with the Company Services may differ depending on the content of the relevant Company Services. The User Information to be collected includes, but is not limited to:

• Customer name;
• Address;
• Telephone number;
• Email address;
• Age; and
• Sex

(2) User Information collected through the Company Services

The Company may obtain the customers’ User Information via the Company Services provided by the Company (e.g., games for PCs, games for mobile devices) and/or through various communications made between the customers and the Company. The User Information to be collected includes, but is not limited to the following; provided, however, that not all of the Company Services necessarily entail the collection of User Information:

• Information that the customers voluntarily register and/or provide on the various online platforms including without limitation SNS platforms provided by third parties (e.g., name, profile photo, user ID, email address, friends)
• IDs specific to the contracting parties/devices (e.g., Operating system-generated ID (Android ID), Unique Device Identifier (UDID), International Mobile Subscriber Identity (IMSI), Integrated Circuit Card ID (ICCID), International Mobile Equipment Identity (IMEI), and Media Access Control (MAC) Address)
• Communication history
• History of online behavior on webpages
• Application use history
• Location information
• Pictures, movies and the like
• Any other information that is reasonably necessary for the Company’s effort to improve the Company Services.

Please be advised that Cookie technology (meaning the system in which the information recorded at the time of use of a website will be stored on the computer of the website user) may be used in the Company Services. Cookies will not store names, email addresses, or any other information that may identify a specific individual, and will be mainly used to quicken the recognition of the computer(s) used by customers or to record the history when customers visit the website. By altering the configuration of a customer’s browser, such customer can disable Cookies or can receive a notification when Cookies are sent to such customer’s computer(s). By doing so, however, such customer may become unable to use all or part of the services on the website.

Purposes of Use of User Information

The Company may use User Information collected from the customers for the following purposes:

1. To verify the identities of customers, or to carry out other authentication procedures in the Company Services;
2. To manage and operate the Company Services, to make various communications made within the Company Services, or anyhow to provide the Company Services;
3. To, without limitation, understand, analyze, or study the needs and tastes of the customers, or to improve the Company Services or to develop new services;
4. To provide customer support regarding the Company Services, to respond to comments and questions from the customers, and to dispatch gifts;
5. To prevent unauthorized use of the Company Services;
6. With regard to the use of the Company Services, to generate statistical data processed into a form in which identification of specific individuals is not possible;
7. To bill usage fees to the customers who have used pay services;
8. To send notices regarding the Company Services and/or promotional information regarding partner companies;
9. To, without limitation, understand, analyze, or study the needs and tastes of the customers, as well as to develop new services, together with the content business-related partner companies carrying out the business in collaboration with the Company.

Manager of User Information

User Information collected by the Company will be managed at the headquarters of KITERETSU Inc., located at Park Axis Aoyama 1-chome Tower #2209, 1-3-1, Minami-aoyama, Minato-ku, Tokyo.

Implementation of Security Management Measures

In order to appropriately handle the customers’ User Information and to prevent the loss, deletion, falsification and leakage, etc., of User Information, the Company will establish a security management system and appropriately supervise its employees, etc., who handle User Information.

Provision of User Information to Third Parties

The Company will not provide any third party with User Information of any person without obtaining the consent of such person; provided, however, that the Company may disclose User Information as required by law, or to those entrusted with its services to the extent necessary for achieving the purpose of use of the same. The services entrusted will include, without limitation:

• In the case of the customer support services being outsourced to external business operators;
• In the case of the dispatching/sending of direct mail notifying various events being entrusted to external business operators;
• In the case of User Information of the customers being entrusted to payment system companies/credit companies as well as the banks that are entrusted with the services of the Company for the purpose of billing the usage fees to the customers using the pay services;
• In the case of the materials to be delivered to the customers being entrusted to external business operators.

Sharing of Information

The Company will share User Information that is deemed necessary for the above-mentioned purposes of use, such as the name, date of birth, sex, and online behavior on the webpage, for the purposes provided in “Purposes of Use of User Information” above, with its subsidiary/affiliates or other group companies or with the content business-related partner companies carrying out the business in collaboration with the Company. For the avoidance of doubt, the Company will be the management representative with respect to the sharing of User Information with the partner companies.

Personal Information of Minors

In the event of a minor using the Company Services and/or inputting User Information, the consent of a custodian is required.

Notification, Disclosure, Amendment, Addition, or Deletion of User Information, as well as Service Suspension

If any person requests, with regard to his/her User Information owned by the Company, that the purposes of use thereof be notified, disclosed, amended, added to or deleted, the Company will comply with such request as soon as reasonably possible upon verifying the identity of the person; provided, however, that the Company may not be able to, without limitation, amend, add to, or delete the User information disclosed on the various platforms.

If any person requests suspension of the Company Services that use User Information, the Company will comply with such request promptly upon verifying the identity of the person.

For the procedures to be taken in such cases, please contact the department in charge as set forth at the bottom hereof.

Change to this Personal Information Protection Policy; Contact Information, etc.

The Company may change the content of this Personal Information Protection Policy without prior notice in order to appropriately protect the customers’ User Information or in line with the amendment of laws and ordinances, including in the event of any change in the content of the business of the Company. Any change will be announced in an easily comprehensible manner, so please confirm the latest content on a regular basis.

Department in Charge of this Personal Information Protection Policy

Department in Charge
Contact Information: KITERETSU Inc., Administration Department
Email address: privacy@kiteretsu.jp